Petitioning the TTB to recognize Muscardin: the 14th and final Chateauneuf du Pape grape in the Beaucastel Collection

This week we are filing a petition to recognize Muscardin for use as a grape variety name on wine labels in the United States. The petition, ready to go out today, includes a letter of support from the Assistant Director of Foundation Plant Services, excerpts from four esteemed reference books on wine, the grape's Wikipedia entry, the original 1936 declaration and the current statute that regulate the Chateauneuf-du-Pape appellation, the entry in Pierre Galet's seminal ampelography Cépages et Vignobles de France with its translation, and even the Beaucastel poster that includes lithographs of the thirteen grape varieties. I hope it's comprehensive enough:

Why, you might ask, do we need to petition to use a grape name on our label? It's because all alcohol labels need to be approved before use by the Alcohol and Tobacco Tax and Trade Bureau (TTB), a division of the Department of the Treasury, and if you use a grape variety name on your label, that (or those) need to be grapes that the TTB recognizes. The regulation setting up this framework was adopted in 1996 by the BATF (the precursor to the TTB), with a clearly stated purpose:

These regulations are intended to provide specific and accurate labeling of grape wines labeled with grape variety names. They are intended to prevent consumer deception by eliminating misnamed grape variety names, and by eliminating the use of many synonyms for prime grape names. They are expected to aid in the identification of grape wines by consumers and to make labels easier to understand through the use of more meaningful labeling terms. Finally, ATF believes these regulations will enable consumers to be better informed about wines and the grape varieties used to produce them. 

That 1996 regulation included a list of 251 recognized grape names, 20 grandfathered synonyms (such as Shiraz for Syrah, Fumé Blanc for Sauvignon Blanc, and Pinot Grigio for Pinot Gris), and 61 grape synonyms whose use was to be phased out within a few years. It also included a mechanism by which any interested party could petition to have the list of grape names amended to add new varieties as they were imported or developed. The criteria for approval are clearly laid out:

1. Any interested person may petition the Director for the approval of a grape variety name. The petition may be in the form of a letter and should provide evidence of the following—
   
   1. acceptance of the new grape variety,
   2. the validity of the name for identifying the grape variety,
   3. that the variety is used or will be used in winemaking, and
   4. that the variety is grown and used in the United States.
2. For the approval of names of new grape varieties, documentation submitted with the petition to establish the items in paragraph (a) of this section may include—
   
   1. reference to the publication of the name of the variety in a scientific or professional journal of horticulture or a published report by a professional, scientific or winegrowers’ organization,
   2. reference to a plant patent, if so patented, and
   3. information pertaining to the commercial potential of the variety, such as the acreage planted and its location or market studies.

This will not be the first petition we have submitted. Back in 2001, my dad petitioned for the recognition of Grenache Blanc, Counoise, and Picpoul Blanc. In 2012, he sent in petitions for four more: Bourboulenc, Picardan, Vaccarese, and Terret Noir. All those were approved, along with 89 others, and are now on the list of the 347 grapes allowed on American wine labels. With this Muscardin petition, we're hoping to make it 348. 

Muscardin's journey to this point has been a long and challenging one. The field cuttings we took from Beaucastel of the seven grapes we imported in 2003 were all found to have virus, and while Terret Noir and Clairette Blanche were released in 2009 after one round of virus cleanup, it took Picardan (released in 2012) two rounds, Bourboulenc, Vaccarese, and Cinsaut (released in 2015) three rounds, and Muscardin four separate rounds of cleanup by the experts at the Foundation Plant Services station at UC Davis. This meant that we didn't get vines to propagate until 2018, and the first buds weren't available to graft until 2019. We grafted five surplus rows of Grenache Blanc over to Muscardin that summer, and got our first small crop -- enough to make just 30 gallons, or one half-barrel -- in 2021. That wine was pale but spicy and red-fruited, with a minty/herby/juniper note, good acids, and nice saltiness on the finish. It was appealing enough that we felt it should go into our Le Complice. It became a part of the blend in June of 2022 and has been sitting in foudre since then. Now that we're getting ready to bottle and label it, the grape needs to be approved.

What do we expect to get from Muscardin? It's more of a hope than an expectation. Muscardin is rare enough in France that there's not a lot of literature on it. When I wrote the Muscardin entry in my Grapes of the Rhone Valley blog series, it turned out that there wasn't a lot of information available, perhaps unsurprising given that Muscardin's total footprint was less than 50 acres worldwide. It was first recognized in 1895, and was included in the list of approved Chateauneuf-du-Pape grapes when the appellation was established in 1936. The best explanation of its value that we've been able to turn up is a great quote from Baron Le Roi of Chateau Fortia that John Livingstone-Learmonth recounts in his 1992 book The Wines of the Rhone: "You know, we would be better off here if we replaced the Cinsault with the Muscardin. The Muscardin doesn't produce a lot, makes wine of low degree and spreads out over the soil, preventing tractors from passing freely between the vines, all of which combine to put people off it. But I believe that it gives a freshness on the palate and helps the wine to achieve elegance." From the one vintage under our belts, that use -- to provide freshness and elegance -- seems like one worth more exploration. 

It's always been our goal to plant and vinify all sixteen grape varieties in the Beaucastel vineyard. This includes the thirteen "traditional" Châteauneuf-du Pape grapes, plus Viognier and Marsanne (allowed in Cotes du Rhone and found in the Coudoulet de Beaucastel section of the property) and Grenache Blanc (covered under the "Grenache" entry but not counted in the tally of thirteen). Now that we're able to take this last step with Muscardin, a foundational goal of my dad's is finally within reach. Hey, it's only taken 34 years.